Cited by
Opinions in Minnesota that cite Sanchez v. State, 816 N.W.2d 550.
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Robert Ian Agarano, petitioner, Appellant,
Minn. Ct. App. 2026
For these purposes, a postconviction claim arises “when the petitioner knew or should have known that he had a claim.”
- State of Minnesota v. Rebecca Lee Treptow Minn. Ct. App. 2026
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State of Minnesota v. Rebecca Lee Treptow
Minn. Ct. App. 2026
A claim “arises” when the petitioner “knew or should have known of the claim.” -60 (Minn. 2012).
- Jacob William Kinn v. State of Minnesota Minn. Ct. App. 2026
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Jacob William Kinn v. State of Minnesota
Minn. Ct. App. 2026
This claim accrues “based on an objective ‘knew or should have known’ standard.”
- State of Minnesota Office of the Attorney General v. Madison Equities, Inc. Minn. 2026
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State of Minnesota Office of the Attorney General v. Madison Equities, Inc.
Minn. 2026
We generally “have no power to extend or modify statutory limitations periods.”
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In re the Matter of:
Minn. Ct. App. 2025
-61 (Minn. 2012) (declining to reach the question when the appellant did not establish entitlement to the equitable relief).
- Travis Clay Andersen v. State of Minnesota Minn. Ct. App. 2025
- Travis Clay Andersen v. State of Minnesota Minn. Ct. App. 2025
- A24-1949 Minn. Ct. App. 2025
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Richard Preston Blackwell, petitioner, Appellant,
Minn. Ct. App. 2025
And this exception relates to the “reason the petition was filed after the [two]-year time limit in subdivision 4(a), not the substantive claims in the petition.”
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Eugene and Sandra Alexander, et al., Plaintiffs,
Minn. Ct. App. 2025
The second type of tolling Minnesota recognizes is equitable tolling, which, under certain circumstances, “allows a court to consider the merits of a claim when it would otherwise be barred by a statute of limitations.”
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Russell Vincent Winbush, petitioner, Appellant,
Minn. Ct. App. 2025
This exception relates to the “reason the petition was filed after the [two]-year time limit in subdivision 4(a), not the substantive claims in the petition.” -36 (Minn. 2021) (stating that the interests- of-justice exception “focuses on why the petition was filed after the [two]-year time limit” and that the petitioner “must allege an injustice that caused the delay in filing the petition” (quotation omitted))
- Albert George McIntosh, petitioner, Appellant, Minn. Ct. App. 2024
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State of Minnesota Office of the Attorney General, Appellant,
Minn. Ct. App. 2024
by some ‘paramount authority’ or by situations arising out of ‘invincible necessity’” from commencing suit.10 (quoting St.
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Minn. 2024
For instance, the court addressed when the limitations period for a petition brought under the postconviction statute, Minn. Stat. § 590.01 (2010), begins to run.
- Victor Cortez Shelton, petitioner, Appellant, Minn. Ct. App. 2024
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Scott Marlin Morey, petitioner, Appellant,
Minn. Ct. App. 2024
The interests of justice provide a petitioner with an exception to the two-year statutory time-bar only if the injustice relates to the reason the petition was filed after the time limit and the injustice caused them “to miss the primary deadline.”
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Travis Clay Andersen, petitioner, Appellant,
Minn. Ct. App. 2024
See Sanchez v. State , d 550, 557 (Minn. 2012).
- Carlos Heard v. State of Minnesota Minn. Ct. App. 2024
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Carlos Heard v. State of Minnesota
Minn. Ct. App. 2024
exception relates to the reason the petition was filed after the two-year time limit, not the substantive claims in the petition; in other words, “the interests-of-justice exception is 15 triggered by an injustice that caused the petitioner to miss the primary deadline in subdivision 4(a), not the substance of the petition.”
- Michael James Rye v. State of Minnesota Minn. Ct. App. 2024
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Michael James Rye v. State of Minnesota
Minn. Ct. App. 2024
d 550, 560 (Minn. 2012).
- Howard William Amos v. State of Minnesota Minn. Ct. App. 2024
- Howard William Amos v. State of Minnesota Minn. Ct. App. 2024
- Edbert Neal Williams v. State of Minnesota Minn. 2024
- Edbert Neal Williams v. State of Minnesota Minn. 2024
- Ronald Lewis Greer v. State of Minnesota Minn. 2024
- Ronald Lewis Greer v. State of Minnesota Minn. 2024
- Kawaskii Antonio Blanche, Minn. 2023
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St. Louis County Gildea, C.J. Tyrone James White, Appellant, vs.
Minn. 2023
But the exception “relate[s] to the reason the petition was filed after the 2–year time limit in subdivision 4(a), not the substantive claims in the petition.” Caldwell, d at 141.
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A22-0300
Minn. 2023
If applicable, “[t]he doctrine of equitable tolling allows a court to consider the merits of a claim when it would otherwise be barred by a statute of limitations.” Sanchez v. State , (discussing tolling under Holland).
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, A22-0057
Minn. 2022
see also Andersen III, d at 428 12 (Minn. 2018).
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Orlando Omar Castillo, petitioner, Appellant,
Minn. Ct. App. 2022
See Sanchez, (“The determination of when [the petitioner]’s interests-of-justice claim arose is a question of fact.”).
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Lincoln Lamar Caldwell,
Minn. 2022
(Minn. 6 We issued our opinion in Caldwell’s direct appeal on August 11, 2011, and his conviction became final on December 10, 2011.
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John Stephen Woodward, petitioner, Appellant,
Minn. Ct. App. 2022
4(c); -58, 560 (Minn. 2012) (holding that claim “arises” when claimant “knew or should have known that [they] had a claim”).
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State of Minnesota, Respondent,
Minn. Ct. App. 2022
d 550, 556 (Minn. 2012).
- Jason Charles Cibulka, petitioner, Appellant, Minn. Ct. App. 2022
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Jose Antonio Martinez-Fuentes, petitioner, Appellant,
Minn. Ct. App. 2022
In Sanchez v. State, the supreme court explained that “the interests-of-justice exception is triggered by an injustice that caused the petitioner to miss the primary deadline in subdivision 4(a), and not to the substance of his petition.” (M inn.
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Matthew William Edwards, petitioner, Appellant,
Minn. Ct. App. 2022
Even when an exception to the two -year deadline in subd ivision 4(a)(1) applies, however, “[s]ubdivision 4(c) creates the additional requirement that a petition invoking an exception provided in [4](b) must be filed within two years of the date the claim arises.” Sanchez v. State , (quotation omitted).
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Shane Paul Schultz, petitioner, Respondent,
Minn. Ct. App. 2022
Sanchez v. State , d 550, 558-60 (Minn. 2012).
- John Steven Martin, Minn. 2022
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Terrance James Bowers, petitioner, Appellant,
Minn. Ct. App. 2021
4(b)(5) (2020) ; see also Hooper v. State , (holding that an interests -of-justice claim “must relate to an injustice that delayed the filing of the petition, not to the substantive merit of the petition”); Sanchez v. State , (same).
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Aka Lawrence Fualefeh, petitioner, Appellant,
Minn. Ct. App. 2021
d 550, 552 (Minn. 2012).
- Kenny Lee Reed, FKA: Gordon David Reese, petitioner, Appellant, Minn. Ct. App. 2021
- Jose Santoya Juarez, petitioner, Appellant, Minn. Ct. App. 2021
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Syrrome James Phylip Moos, petitioner, Appellant,
Minn. Ct. App. 2021
Such a claim arises when the petitioner “knew or should have known that he had a claim.”
- A20-0206 A20-0228 A20-0229 Minn. 2021
- S’Emaj Avyiair Okongwu, petitioner, Appellant, Minn. Ct. App. 2021